As discussed in a previous blog, a hospital’s Supplemental Security Income (SSI) percentage is a primary component of Medicare Disproportionate Share reimbursement and plays a significant role in determining the reimbursement impact. Also referred to as the “Medicare” fraction of the Medicare DSH calculation, the SSI ratio represents the percent of patient days for beneficiaries who are eligible for both Medicare Part A and SSI. By default, SSI ratios are based on the Federal Fiscal year end (10/01 – 09/30) and are generally published annually by the Centers for Medicare and Medicaid Services (CMS). Current CMS regulations allow for a hospital to request to have its Medicare fraction or SSI ratio recalculated based on the hospital’s cost reporting period where different from the Federal fiscal year, however, a hospital may be hesitant to request due to common misconceptions surrounding SSI recalculations. Here are four we commonly hear:
1. For starters, a common misconception is that if a hospital requests a recalculation for one cost reporting period, they are obligated to do so going forward for subsequent cost reporting periods. This is certainly not true, as stated in the FFY 2006 Final Rule published by CMS:
“…we are not requiring hospitals to select either the Federal fiscal year or their cost reporting period and use that selection for each subsequent year. A hospital may opt to use the data from either time period each year.” - CMS
So, each fiscal year is truly independent from the next in regards to SSI recalculations; specifically, if a provider requests a recalculation for one fiscal year, they are not required to request a recalculation for any prior or future years.
2. In order to determine if a hospital would benefit from an SSI recalculation for a given fiscal year, MedPAR patient detail must be requested and analyzed. Another misconception is that originally, providers could request this data only if they had a properly pending DSH appeal(s) before the Provider Reimbursement Review Board (PRRB). However, beginning with cost reports ending on or after December 8, 2004, CMS no longer requires hospitals to have pending DSH appeals in order to request the MedPAR data.
3. A third misconception is that stakeholders can attempt to estimate potential impacts from an SSI recalculation by simply identifying provider fiscal years where their SSI percentage increased from one year to the next. SSI recalculation impacts and trends are difficult to forecast for any provider without a thorough analysis of the actual MedPAR routine use data, which upon request, is often released several months after CMS releases the annual SSI percentage tables (see FFY2013 SSI percentage tables HERE). Routine use data detail must be obtained and correctly analyzed to accurately calculate and prepare a request for an SSI percentage redetermination from Federal fiscal year to hospital year end. See our post on determining if you benefit from an SSI recalculation HERE.
4. Finally, the SSI recalculation issue is not contingent upon litigation or appeal. As long as the request is made prior to the close of the hospital’s 3-year cost report reopening window and the proper supporting documentation accompanies the request, then the hospital should expect to eventually obtain the favorable, recalculated SSI percentage incorporated within a future NPR.
Hospitals (and/or their consultants) should research annually whether their facility could benefit from an SSI realignment. In addition to Medicare DSH reimbursement reviews, SCA has vast experience in facilitating SSI recalculation data analyses and requests on behalf of its clients and has performed hundreds of SSI redetermination requests to date. Please contact us to learn more about this service and how SCA can help you determine if an SSI enhancement is in the best interest for your hospital. Don't forget to subscribe to our blog so you don't miss future posts in our SSI recalculation series!
